FCC Announces MLTS ECS NOI Agenda

My role at Avaya is to manage the product various offerings as they pertain to public safety solutions in the enterprise. Additionally, this includes public safety answer points. From a legislative and regulatory perspective, I work with various agencies. These include the Federal Communications Commission, as well as recognized standards development organizations, known as SDOs, like NENA, the National Emergency Number Association, EENA, the European Emergency Number Association, and APCO International, the Association of Public Safety Communications Officials.

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This particular work is probably the most important of what I do. It sets the stage for legislative guidance within the industry, ensuring that best practices and technically feasible solutions are specified and deployed.

In the United States, the Federal Communications Commission regulates interstate and international communications that take place by radio, television, wire, satellite, and cable in all 50 states, the District of Columbia and US territories. The FCC is an independent US government agency that is overseen by Congress and has been designated as the federal agency that is responsible for implementing and enforcing America’s communications law and regulations.

So how does Rulemaking work at the FCC?

Each time that Congress wishes to enact a particular piece of legislation that affects telecommunications in the United States, the FCC is tasked with developing rules to implement any specific law required to codify that legislation. To carry out its work, the Commission will then take specific regulatory steps to formulate and enforce these rules.

Fortunately for US Citizens, these steps offer consumers an opportunity to submit comments as well as reply comments to the FCC to be considered during the process.

The Commission’s decision-making process is well defined, albeit brings forth a whole new chapter in the ‘Alphabet Soup’ served as a daily special served at Chez’ Telecom. Here is a quick guide to understanding the “alphabets” of the FCC.

  • Notice of Inquiry (NOI): The Commission releases an NOI to gather information about a broad subject or as a means of generating ideas on a particular issue. NOIs are initiated either by the Commission or an outside request.
  • Notice of Proposed Rulemaking (NPRM): After reviewing comments from the public, the FCC may issue a Notice of Proposed Rulemaking. An NPRM contains proposed changes to the Commission’s rules and seeks public comment on these proposals.
  • Further Notice of Proposed Rulemaking (FNPRM): After reviewing your comments and the comments of others to the NPRM, the FCC may also choose to issue an FNPRM regarding specific issues raised in comments. The FNPRM provides an opportunity for you to comment further on a related or specific proposal.
  • Report and Order (R&O): After considering comments to a Notice of Proposed Rule Making (or Further Notice of Proposed Rule Making), the FCC will issue a Report and Order. The R&O may develop new regulations, amend existing rules or make a decision not to do so.

Summaries of the R&O are published in the Federal Register. The Federal Register summary will tell you when a rule change will become effective. Not quite as entertaining as general legislation, and we have no “I’m just a Bill” theme song, but the process is efficient, and most importantly gets public and commercial input, as well as the contribution of specific experts to the legislation at the very start.

On Tuesday, September 26, 2017, Chairman Ajit Pai has announced that the September Open Meeting will include an agenda item:

911 Access, Routing, and Location in Enterprise Communications Systems
The Commission will consider a Notice of Inquiry that seeks comment on the provision of 911 by enterprise communications systems that serve businesses, hotels, educational institutions, and government entities.

This will be heard under Public Safety and Homeland Security Docket 17-239 and is a direct result of the issues raised by Avaya on behalf of Hank Hunt, Kari’s Dad. Around the world, this is commonly known as Kari’s Law and has over 650,000 supporters on Change.Org after Hunt created the petition after the tragic death of his 31-year old daughter Kari Hunt, on December 1, 2013, in Marshall Texas. Kari’s 9-year old daughter knew to dial 9-1-1 from the hotel room phone but was unable to because a ‘9’ was needed for an outside line. Versions of the Bill have passed the House and US Senate and are ready to be joined and sent to the Whitehouse.

In addition to the important aspects defined by Kari’s Law, Direct Access, On Site Notification, and Routing without Interception, this new FCC NOI covers additional important aspects, including affordable implementation, management and testing of solutions. For more information on the FCC Proceeding, you can watch the September Open Meeting LIVE on the Internet at http://fcc.gov/live, and the public is welcome to attend in person at the FCC, 445 12th Street SW, Washington, DC 20554.

For more information about Kari’s Law, you can visit the Kari Hunt Foundation at  https://www.KariHuntFoundation.com where you can read the story, and contribute to their cause in educating the public so a child is never faced with the situation where 911 will not reach public safety on the phone.

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Is Text Messaging Just Dying or Dead?

The United States Computer Emergency Readiness Team (US-CERT) will be dropping support for Short Message Service SMS in favor of email alerts going forward. Is this a sign of the times? Is texting getting too long in the tooth, and are citizens looking for other more multi-media rich content? The following letter was distributed today advising of the discontinuance of the popular service via SMS. This makes me wonder if Text to 911 hasn’t missed the boat with only about 20% of the PSAPs being deployed with the functionality. Should they be focusing on multimedia and omnichannel communications from the public?

U.S. Department of Homeland Security US-CERT

US-CERT to Discontinue SMS Text Messages

US-CERT will be discontinuing SMS text messages (wireless alerts) this month. To ensure you continue receiving the latest information about security topics and threats, please update your subscriber profile to include an email address. Alternatively, subscribe here using your email address.

If you’re receiving this notification via email, you do not need to take any action. As we approach October, National Cyber Security Awareness Month, consider sharing the following link with friends and family so that they can stay current on risks potentially affecting their systems and data: https://www.us-cert.gov/ncas. At the bottom of every US-CERT.gov webpage is a link to subscribe to email alerts.

Affected topics:

  • National Cyber Awareness System Mailing Lists
    • Alerts
    • Bulletins
    • Tips
    • Current Activity
  • Industrial Control Systems Cyber Emergency Response Team (ICS-CERT)
    • Alerts
    • Advisories
    • Announcements
    • Year in Review
    • Monitor Newsletter
  • Critical Infrastructure Cyber Community Voluntary Program (C3VP)
    • C3VP Updates

Please contact info@us-cert.gov with any questions or concerns. Thank you.

United States Computer Emergency Readiness Team (US-CERT)

6 Easy Steps to Protect your PBX from a Hurricane Related Outage

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6 Easy Steps to Protect your PBX from a Hurricane Related Outage

As the US and Caribbean prepare for Hurricane Irma, we want you to know that Avaya and our team is by your side and available to help now and after the storm passes. We are committed to your business. Our sales teams and employees are here to help preserve critical business operations. Please contact the Avaya Support Website for specific proactive support information.

Avaya recommends reviewing the following 6 steps available on Avaya’s support website as a helpful reminder for final preparations:

  1. Save translations before the emergency event impacts the site.This will ensure that recent changes are not lost and speed restoration in the advent of damage to the system.
  2. Review safety procedures with all employees prior to the emergency event, if possible, and make certain to have an updated contact list to keep in touch.
  3. Secure back-up mediaso that translations won’t be lost or damaged, thereby delaying restoration of your service. Take a copy of back-ups and any other information off site.
  4.         Print and store a current list configuration of key solutions.If a new system is necessary, this simple precaution will save time in starting the process.
  5.         Consider powering your system down before the emergency event impacts the site Electrical power surges both before and after an emergency event can pose the greatest threat to your system.
  6.         Contemplate moving switch/applications if the site is located in an area that may be exposed to damage from the emergency.

FEMA Hurricane Status

For the most current information on the status of Hurricane Irma and information on precautions you and your family can take in advance, please refer to the Federal Emergency Management Agency (FEMA) website at www.fema.gov.

Click here for the National Hurricane Center: www.nhc.noaa.gov


Our first priority is your safety and we stand by ready to support your business continuity and disaster recovery needs now and in the future.



Back 2 School Safety Preparedness

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The ABCs of Back to School Preparedness

Back to School Preparedness

With school bells ringing across the Nation, it is time for parents and guardians to get familiar with the emergency plan at your child’s school or daycare.

Much like individuals and families, schools and daycare providers should all have site-specific emergency plans. If you are a parent or guardian, it is important to make sure your child’s school or daycare has a plan to ensure his or her safety during an emergency.

The Centers for Disease Control and Prevention (CDC) outline steps as easy as ABC to keep your child safe at school or daycare:

  • Ask how you will reunite with your child in an emergency or evacuation.
  • Bring extra medication, special foods, or supplies that your child might need.
  • Complete a backpack contact information card.

 If your child has an access or functional need, be sure to meet with a school official to discuss plans for how the school will provide for his or her safety. For more information about emergency preparedness for parents, educators, and kids, visit www.ready.gov/kids.

Parents, guardians, and teachers can also use the Children and Youth Preparedness Social Media Toolkit to share safety messages on their social media networks.

Avoiding Disaster Fraud

FEMA Credentials

After a disaster, many community-based organizations come together to support the needs of those affected. Unfortunately, individuals with ulterior motives may also prey on those disaster survivors by offering fraudulent services.

Learn how to protect yourself and your finances from additional loss. The Federal Emergency Management Agency (FEMA) offers reminders to help you avoid disaster fraud, including:

  • Do not pay a fee to apply for FEMA disaster assistance or to receive it. FEMA does not charge a fee for these services.
  • Get three written estimates for repair work. Check credentials, and contact your local Better Business Bureau or Chamber of Commerce to learn about any complaints against the contractor or business.
  • Make sure you obtain a written contract detailing all necessary services and costs before work begins. The contract should also have a projected completion date and outline ways to negotiate changes and settle disputes.
  • Pay only by check or a credit card. A reasonable down payment may be required to buy materials for some projects, but do not pay anything without a signed contract.

Be sure to check out the full list of disaster fraud tips and stay vigilant when disaster strikes. To register for FEMA disaster assistance, call 1-800-621-3362 (TTY: 800-462-7585) or visit www.DisasterAssistance.gov.

5 Secrets to the Business Side of 911

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With any innovation, comes the opportunity for additional technology. At times, the technology is a welcome addition, while at other times it’s merely an opportunity for marketing. Take the mobile telephone market for example. In an October 2015 article by ABI Research, they stated that they expect that “global revenues for mobile accessories will reach US$81.5 billion in 2015 and is forecast to grow to $101 billion in 2020 at a compound annual growth rate (CAGR) of 4.3%.” protective cases topped the market followed by chargers, screen protectors and finally headsets.

Screenshot 2017-08-19 13.25.20

In 1969, 911 eliminated the challenge of knowing the local telephone number of the police, fire, or ambulance service in an emergency. More than a decade later, Caller ID was added to identify who was calling. Access to the Selective Router and the billing database, containing the address of the call was now party of the E911 system, and worked well. This ‘Enhanced 911’ model worked well, and E-911 service began rolling out across the entire country.


All was well with public safety and their shiny new E911 system, until the mobility monster reared its ugly head. Mobility is the enemy of 911. It breaks the simple model of a phone number relating to a specific location or address. Cellular telephones, and business VoIP systems, allow users to be located anywhere network connectivity is available. From this an entire new market was born, “The Enterprise 911 Solution Provider”. Both CPE and Cloud based solutions can be purchased, and monthly services can be established for users on the system. These services supposedly track movement, and update the appropriate public safety databases with required information. And, as with any opportunity, comes the opportunity to be sold a bag of magic beans.

Understanding how 911 works, in its simplest form, will allow an administrator to procure the appropriate solution for their business environment.

MYTH 1: I need 911 service on every device
While it’s true that every device needs direct access 911, having a 911 record (a.k.a. phone number) for each device is not required. The phone number sent to the 911 center will trigger a specific address record to display on their computer terminal. What is important, is that each telephone device sends a caller ID that is relevant to their location, so dispatchers see the appropriate address.

What they don’t want you to know:
Their billable is the telephone number, and they will give you every reason in the world to get you to put as many of those in the database. While some reasons may have merit, most reasons are there to scare you based on your lack of understanding.

MYTH 2: 911 Needs to call back the specific device that dialed 911
It is critical that 911 dispatchers can re-establish a connection in the event of the call to 911 getting disconnected. More information may be required, a clarification on the address may be needed to get responders to the right location, or important instructions may be given to assist while help is arriving. Who needs to get that call, though, is up for debate.

With On-Site Notification, a responsible party can be made aware of a 911 call event, and then be able to handle any additional information requests. They can be a trained person who has access to all information and provide better coordination with emergency responders. And they are in the best position to direct any local personnel that may be qualified to assist while waiting for help to arrive.

What they rather you don’t realize:
Being able to call every station directly, means a phone number on the device in the 911 database, and again, recurring billing, or a ‘gateway device’ in the path of the call.

MYTH 3: 911 is better provided in ‘the Cloud’ or as a ‘Hosted Service’
The cloud is a wonderful place. It is the answer to the ultimate question of Life, the Universe, and Everything, no . . . wait . . . that was 42. It is still a very cool place though, and provides a lot of benefit. And while 911 can live in the cloud, the question remains if you need, or want it too, in your implementation. The cloud buys you a single point of access for emergency services across your network, but of the network is down, so it E911. The cloud gets you to every 911 center in the US and Canada, but you need to access the cloud via SIP or a 10-digit phone number. The Cloud can provide notification and email alerts, but the cloud is external to your facility so it may not be available in an urgent situation where a phone system on premises may serve your needs better. The decision is up to you, based on your needs and concerns.

What they don’t want you to know:
Again, if a 911 provider billable is a telephone number, don’t let them force your need for the cloud to have an entry for every device. The cloud can easily operate on a building or zone level.

MYTH 4: If I buy a system it will send Public Safety detailed information
If it were only true, but it isn’t because of this one reason. 911 is a voice call. The 911 network is a voice network. There is NO DATA CHANNEL, there is no pathway for anything but voice. 911 can receive caller ID, and then reference a database for static information that was put there before the call was made.

What you need to understand:
The 911 database contains records for each phone number, we know this already from the previous myths. In that record, there is a single 40-character free form field that can be populated with specific location text. You thought Twitter was tough with 140 characters, try to be specific with 40 or LESS!

MYTH 5: You are NOT part of the solution
When it comes right down to it, not only are you a critical part of the solution, you are the one that is most important part of the solution. YOU understand the layouts of your buildings, YOU can coordinate resources inside your facility to render the best assistance possible, and YOU are able to provide access to the other tools that already exist that can provide the valuable situational awareness that can be correlated and given to 1st responders when they arrive on site.

What they don’t want you to know:
All the information provided here, because this removes the vail of secrecy that guards the profits these companies make from fear uncertainty and doubt.

Using an external provider may be the right thing for your company, it comes down to the use case and requirements. And while sometimes you can get by with the functionality built into the system, if you do need a partner, make sure they are DevConnect Tested and Approved for the release and version of your system, and carry the DevConnect Partner or SELECT Product Partner logo.

If you are making an educated decision, and implementing 911 to a level that is effective, you are in line with the law, and good to go, in my book. Just beware of predatory tactics and the proverbial wolf in sheep’s clothing.


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Another Year of Waiting – Mobile Devices Still Can’t Be Found – or Can They?

Why is it that sometimes the most simple things, take the longest to implement? It is not technology, it is not innovation, it is not patent lawsuits. Is it the almighty $$ or Euro as it may be? One has to wonder sometimes. in 2012, Tim Kenyon of Conveyant Systems, and I presented a new concept to the FCC called Over The Top 911. It was an innovative way of providing MLTS data to PSAPs over a secondary internet channel, in parallel with the call.

Just 2 years ago, at the NENA Public Safety show in Denver, Colorado, a colleague of mine and I demonstrated iLOC8 (i-Locate) a version of this same technology that could be deployed at PSAPs to collect rich multi-media as well as discrete caller location from the millions of cell phones calling 911 each day. A demo of that technology can be seen here:

EENA, the European Emergency Number Association, NENA’s European cousin, reminds us today that in June 2016, Google updated all Android smartphones in the world with Advanced Mobile Location (AML), a technology that allows emergency services to accurately locate a caller in danger. Fast forward a year later, the service has been activated in many countries with many lives saved as a result (see here).

In the past months, EENA has been traveling around Europe to raise awareness of AML in as many countries as possible. All these meetings brought up a recurring question that EENA had to reply to: “So, what about Apple?”. For months, EENA has tried to establish contact with Apple to work on a solution that automatically provides accurate location derived from iPhones to emergency services and rescuers. Unfortunately, with no result.

Emergency services themselves, as well as other stakeholders, are publicly stressing the need for Apple to work on AML. This is the case in Australia, Estonia, Sweden, and Belgium. Belgium announced the launch of AML for Android users on 13 July but indicated that iPhone users should download the “112BE” smartphone app since the service is not available to Apple customers.

Politicians have also stressed the need for AML to be available in all handsets. In an interview with EENA after her visit to the 112 Emergency Response Centre in Tallinn, Member of the European Parliament Kaja Kallas noted that “Currently, AML only works on Android devices. To increase the number of people who can benefit from it, we should make sure that it works on all smartphones.”.

EENA recognizes the efforts of Apple to improve the safety of their customers. The SOS functionality of the Apple Watch can automatically send the location of a caller to a specified contact. Nevertheless, this functionality should be extended to mobile phones, and the location should be sent to emergency services and rescuers as well – the people who primarily need this information. Recent news about the “panic command” on iPhones, including a location function, is also a step in the right direction. But it is not sufficient: accurate location information should be sent during all emergency calls.

As AML is being deployed in more and more countries, iPhone users are put in a disadvantage compared to Android users in the scenario that matters most: an emergency.

EENA calls on Apple to integrate Advanced Mobile Location in their smartphones for the safety of their customers. It is important to highlight once again that AML is an open-source protocol (see ETSI technical report here) and any smartphone manufacturer or operating system provider can integrate it in their products.

EENA remains at the disposal of Apple to work together on a solution that will concretely improve the safety of its customers.


AML is an open-source protocol that improves the location data transmitted to emergency services. When an emergency call is detected in the user’s phone, accurate location information derived from the handset is transmitted automatically to the emergency services (using GNSS or Wifi) via SMS or HTTPS. The location data is sent directly to the public authority (emergency services) with no third party having access to it.

Useful links:
About AML: here
AML Frequently Asked Questions: here
ETSI technical report on AML: here
Cases of people saved thanks to AML: here

C’mon Cupertino – Get on Board for Humanity’s Sake – Let’s use our technology and skills to save a few lives right here in the US, and reduce the costs to deliver discrete and precise information to the PSAPs we have today. With NG911 right around the corner, this fit’s right in.


Big Brother might be coming in the future but Little Sister Alexa is here NOW

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Ever since I was a small child, growing up in the 60s and 70s, the future always held in it a device, entity, or artificial being that knew all and saw all. Commonly, it was referred to as “Big Brother”. While there’s no denying that Artificial Intelligence, at a widescale deployment, is on the immediate horizon, it’s quite apparent that elements of that exist today and are quickly becoming embedded in our daily lives.

Thanks to Apple, Siri has been helping me on a daily basis do the most mundane things. Stopping by a colleague’s house while on a recent trip to Santa Clara, “Hey Google:” was the catchphrase of the evening as we all enjoyed this magical box on the kitchen counter answering nearly every question we could throw at it, including, “Hey Google, what’s my name?” for my colleague and his wife who had trained their voices on the app.

Early in July this year, an incident in New Mexico happened where an Amazon ECHO apparently called 911 on it’s own, sort of . When I first read the account, I immediately debunked it knowing that the Amazon Echo doesn’t have the capability of making a phone call over the public switched telephone network. Within a few days, Amazon spokespeople had confirmed this fact, however the story continued, fueled by misquotes, and misunderstood quotes made by the local police department who quickly retracted and corrected some of their initial statements about Alexa initiating a 911 call.

Just as the national news was starting to calm down, Wired Magazine published the story, “An Amazon Echo Cannot Call the Police – But Maybe It Should”, opening Pandora’s proverbial box. Those that are technically savvy may ask why we don’t use technology to automate our lives making processes easier. Those on the opposite end of the spectrum will question privacy invasion capabilities of these devices. Despite valid arguments on both sides of that coin, the problem at hand for public safety officials is the potential volume of calls and false calls that they will receive.

In my days as a police dispatcher in the early 80s, a motor vehicle accident on the highway may end up generating a couple of phone calls and a few shout outs on the CB Radio. Today, with the CTIA saying cellphone saturation is at a record 120.6% for 2016, it’s not uncommon to receive 20 or 30 calls for a single incident such as a motor vehicle accident. Based on this, the sheer number of reports coming in on each incident can cripple even a midsize agency, let alone the vast majority of 911 Public Safety Answering Positions that are staffed with 4 to 6 people or less, when fully staffed.

Based on this, the question at hand is not one of the current capabilities of the technology, rather a questions now become more policy and procedure driven, such as:

  • How we make sure that public safety staffing is at a level that has the ability to receive this new influx of emergency, and nonemergency traffic?
  • How do we make sure we don’t accidentally TDoS the 911 network by enabling potentially millions of attack points in households across the nation?
  • How do we ensure that location information is properly provisioned and utilized, especially if these devices are connected through the IP network and Internet?

Is Big Brother watching? Not likely, at least not today.
Is Little Sister watching? The answer to that might shock you, and the real issue at hand is, if she is, who is she telling?